Document BYKBzGjoXmj662nL0rJoGOqm

such shipments and other information required to indent!fy [sic] each such shipment; (h) The department and officer or employees of plaintiff's employer who: (1) Placed the order; (2) Accepted delivery. (i) defendant who: The department and officer or employee of (1) Accepted the order; (2) Packaged the order; (3) Shipped the -order; (4) Has possession at the present time of the records concerning such shipment. ANSWER: Abex objects to this interrogatory on the grounds .it is overly broad, unduly burdensome and assumes facts not yet established. Subject to and without waiving these objections, invoices which may or may not indicate sales of asbestos-containing automotive friction products to the plain tiff's employer are on file for a period beginning sometime in 1976 to the present only. Such invoices, which number in excess of 800,000, are arranged for the most part in numerical and chronological order by year and not by customer, product or state. These invoices can be made available for inspection and copying upon receipt of an appropriate document request. 18. With regard to each order of asbestos products sold, delivered or supplied by defendant to plaintiff's employer, state whether: -15-